Mondaq Canada: Wealth Management
Traditionally, the view has been that the right to set off one debt against another does not constitute a security interest but it may be that this position is no longer as clear cut in light of the recent Canadian Supreme Court ruling in Caisse populaire Desjardins de l’Est de Drummond v. Canada, 2009 SCC 29 ("Caisse populaire")
Blake, Cassels & Graydon LLP
The Canada Revenue Agency (CRA) opened its Offshore Tax Informant Program (OTIP) on January 15, 2014.
Campbell Valuation Partners Limited
The transfer of business ownership from one generation to the next can be a challenging task.
Dentons (Canada)
A description of the important considerations for business owners regarding estate planning.
Crowe Soberman LLP
As a family-business advisor, whenever I meet with clients, we invariably discuss their goals, objectives and yes, even their dreams.
Crowe Soberman LLP
Stan and Gloria arrived for their yearly meeting with Jennifer, their accountant, to review their business interests and other financial matters. This meeting, though, had a different focus than usual.
Fasken Martineau
On October 25, 2012 the Canadian Securities Administrators ("CSA") published for comment Consultation Paper 33-403 which discusses the potential benefits and feasibility of imposing a statutory fiduciary duty on advisers and dealers to act in the best interests of clients.
PwC Management Services LP
If you are a beneficiary of a non-resident trust (NRT) or contribute property to one, you could find yourself in hot water with the Canada Revenue Agency (CRA).
PwC Management Services LP
Family trusts can provide many benefits and are set up for various reasons.
Fasken Martineau
On June 14, 2012, the Canadian Securities Administrators (CSA) published for comment a second version of amendments to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (NI 31-103) with respect to the second phase of the Client Relationship Model initiative (CRM II).
Fasken Martineau
On July 5, 2012, the Ontario Securities Commission, the Autorité des marchés financiers and the Financial Services Regulation Division, Service NL, Government of Newfoundland and Labrador released Multilateral Instrument 32-102 Registration Exemptions for Non-Resident Investment Fund Managers (the Multilateral Instrument or MI 32-102) and related companion policy.
Moodys Gartner Tax Law LLP
Our firm's June 21, 2010 blog (yes, that's over two years ago), discussed the CRA's domestic trust audit project. Our February 9, 2011 blog discussed the CRA's high net worth audit initiative (or what the CRA calls the "Related Party Initiative" or "RPI" for short).
Veracap M&A International Inc
A common metric used in valuing a business is a multiple of Earnings Before Interest, Taxes, Depreciation and Amortization ("EBIDTA").
Blake, Cassels & Graydon LLP
The Supreme Court of Canada (the SCC) released its decision in Fundy Settlement v. Canada (a.k.a. St. Michael Trust Corp. or Garron Family Trust).
McCarthy Tétrault LLP
Equally, the preliminary determination of what to outsource itself needs to be made carefully. Users very often retain a consulting firm that is independent of any outsourcing vendor to assist in this decision. This is an important threshold stage in the entire outsourcing process. You can make mistakes at this stage from which it is very difficult to recover, however well you negotiate the ultimate outsourcing agreement.
McMillan LLP
The Canadian hedge fund industry has grown dramatically over the past decade. Where previously there were only a few participants in the Canadian hedge fund space, today there are several highly skilled Canadian hedge fund managers - many of which are ready to export their expertise globally.
Osler, Hoskin & Harcourt LLP
A welcome clarification of the duties owed by Canadian directors, the top court’s decision in Peoples v. Wise also highlights the importance of transparency, diligence, prudence and process in reaching reasonable business decisions.
Blake, Cassels & Graydon LLP
Every director of a corporation, regardless of whether it is a publicly traded corporation or a closely held private corporation, is subject to a common law fiduciary duty to act loyally and in the best interests of the corporation.
McMillan LLP
One of the most difficult assets to deal with in an estate plan is a family cottage. Although you may want to keep the cottage in the family, it is often difficult to develop a plan that is tax-effective and that ensures equitable enjoyment of this asset by those family members who have an interest in maintaining it.
Blake, Cassels & Graydon LLP
Widespread use of the depository system in Canada and the U.S. imposes practical limits on income trusts’ ability to monitor and control non-resident ownership of their units. Many income trusts are subject to restrictions on the ownership of their units by non-residents of Canada .
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Moodys Gartner Tax Law LLP
This article provides an introduction to the Foreign Account Tax Compliance Act for Canadians and analyzes Canada’s implementing legislation regarding FATCA.
Crowe Soberman LLP
Form T1135 is the "Foreign Income Verification Statement," which must be filed on an annual basis by taxpayers (including partnerships) who own "specified foreign property" and such property has a cost of over $100,000 at any time during the year.
Davies Ward Phillips & Vineberg
Form W-8BEN-E is a critical component of foreign entity compliance with the Foreign Account Taxpayer Compliance Act.
Over the past six years, the United States has become increasingly concerned that Americans are stashing money offshore, essentially evading U.S. tax.
The Foreign Account Tax Compliance Act is a complex reporting and withholding regime enacted by the U.S. government in March, 2010.
Davies Ward Phillips & Vineberg
The IRS has improved its programs that enable U.S. citizens living abroad to become compliant with their U.S. tax filing obligations.
Fuller Landau
Since the global economic crash of 2008, the Internal Revenue Service (IRS) in the U.S. has been trying to find other ways to generate income and much needed revenue.
Moodys Gartner Tax Law LLP
One thing is for sure… Canadians continue to invest significant amounts of money in the US.
WeirFoulds LLP
Part II of this article will appear in the next Client Update Newsletter and will discuss other conditions for making a valid disclosure and how to participate in the VDP.
Moodys Gartner Tax Law LLP
On August 29, 2014, the Department of Finance released 100+ pages of draft legislation. Much of the draft legislation was to enact the 2014 Federal Budget proposals.
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